Cypruss Cyprus Investment Programme vs. EU Alternatives 2025: Strategic Realignment after the Reform

Let me be frank: When the Cyprus Investment Programme (CIP) was suspended in November 2020, it came as a shock for many of my clients.

Not because they lost money. But because one of the most attractive routes to EU citizenship suddenly disappeared.

But what’s the real story?

After five years in the post-CIP reality, I can tell you: This suspension may have been the best thing that could’ve happened to investment migration in the EU.

That might surprise you. But let me explain why I think so—and which strategic alternatives have emerged as a result.

As someone who’s been building international tax structures for over a decade, I’ve witnessed the evolution of investment migration programs first hand. CIP was certainly attractive: an EU passport for around €2 million, with no residence requirement.

But it had one decisive flaw: it simply wasn’t sustainable.

Today, we find ourselves in a completely new landscape. The remaining programs have professionalized, due diligence is stricter, and frankly: the quality of options has improved.

Ready for an honest reality check?

Then let me show you what’s truly possible after the CIP reform—and how to smartly adapt your strategy.

Yours, RMS

The End of an Era: Why the Cyprus Investment Programme Really Failed

Before we discuss alternatives, we need to understand why the Cyprus Investment Programme was suspended in the first place.

You probably know the official line: criticism from the EU Commission, concerns about money laundering, poor due diligence.

The truth is more complicated.

The Systemic Weaknesses of CIP

The Cyprus Investment Programme ran from 2013 to 2020, granting around 4,000 EU passports during that time. The issue wasn’t the volume, but the system itself.

Here are the critical weaknesses:

• No residence requirement: Investors gained EU citizenship with zero ties to Cyprus
• Insufficient due diligence: Background checks were superficial and not standardized to EU levels
• Political involvement: High-profile politicians were involved in marketing the program
• Opaque property valuations: Developers often inflated prices
• Lack of EU coordination: Cyprus acted without consulting Brussels

The straw that broke the camel’s back was an Al Jazeera undercover investigation in August 2020, exposing how Cypriot officials were willing to grant citizenship even to convicted criminals for a fee.

That was the end.

What Happened to Existing Applications?

This got interesting for everyone still in the pipeline at the time:

Applications filed before November 1, 2020, could still be processed—but under tighter conditions. That resulted in a rejection rate of about 30%, much higher than previous years.

Investors who’d already committed €2.15 million suddenly faced a dilemma: money gone, no passport.

Many of my clients back then asked, “Richard, what do we do now?”

My answer, even then, was: “We look ahead.”

What the Suspension Means for Existing and Prospective Investors

Let’s keep it pragmatic: The end of CIP was a shock to the investment migration industry at first, but a blessing in the long run.

Why?

Increased Credibility of the Remaining Programs

After CIP was suspended, the EU Commission took a close look at all remaining Citizenship by Investment (CBI) and Residence by Investment (RBI) programs. The outcome: much stricter standards.

Malta was required to fundamentally reform its Individual Investor Programme (IIP). Portugal introduced tougher due diligence. Greece professionalized its Golden Visa program.

The bottom line: The programs that survived are far more robust and sustainable.

New Focus on Genuine Residency

The biggest change: A shift from “fake residency” to actual ties with the destination country.

That may sound like a disadvantage at first. But honestly: if you want the benefits of the EU, you should be ready to build genuine European ties as well.

For my clients, that meant a complete change of strategy:

The Hidden Advantages of the New Reality

Here’s my perhaps most surprising insight: For strategically-minded entrepreneurs, the new reality is actually better.

Why?

1. Tax integration: Real residency enables optimal tax planning
2. Business development: Time to build a sustainable business in the EU
3. Political stability: Programs are EU-compliant and sustainable
4. Lower overall costs: Residency programs are often cheaper than CBI
5. Flexible strategies: Multiple programs can be combined

Which brings me to the crucial question: What alternatives are available to you today?

EU Alternatives at a Glance: Which Golden Visa Programs Still Work?

The good news: Even in 2025, the EU still offers attractive options for investment migration.

The less good news: You have to be more strategic than before.

Here’s my overview of the currently available programs:

Active EU Investment Migration Programs 2025

But a word of caution: The table only shows the basics—the real challenges are in the details.

My Honest Assessment of the Top 3 Options

After five years of post-CIP experience, I generally recommend focusing on three programs:

1. Portugal Golden Visa: Best balance of cost, flexibility, and EU access
2. Malta IIP: Fastest route to EU citizenship, but pricey
3. Greece Golden Visa: Most affordable option with EU residency, but a long wait for citizenship

Why not recommend all of them? Simple: Time and resources are limited. It’s better to do one program right than three half-heartedly.

Let’s look at each top option in more detail.

Portugal Golden Visa 2025: The New Reality After the Reforms

Portugal was already popular before the CIP suspension. Now, it’s become the top choice for many.

But a few things have changed here, too.

What Changed in 2024/2025

The most significant change: As of October 2023, real estate investments in Lisbon and Porto are no longer permitted. The rules of the game have totally changed.

Your current investment options:

• Properties outside major urban areas: €500,000 (or €400,000 if in need of renovation)
• Investment funds: €500,000 in Portuguese venture capital or private equity funds
• Research & development: €500,000 in R&D activities
• Company creation: €500,000 plus at least 10 jobs
• Cultural projects: €250,000 in art or culture projects

My honest take? For most entrepreneurs, the investment funds option is the most practical.

Why?

Portugal Investment Funds: My Recommendation for Strategic Investors

Here’s how it works: With €500,000 in a qualifying Portuguese fund, you can achieve three goals at once:

1. Golden Visa eligibility: Fulfills the investment requirement
2. Professional asset management: Your money is actively managed
3. Potential returns: Historically 4-8% per year

The process: You invest €500,000 in a fund authorized by the Portuguese Financial Supervisory Authority (CMVM). After five years, you can withdraw—with any gains accrued.

The residency requirement is minimal: Just 7 days in year one, then 14 days every two years thereafter.

In practical terms, you can continue to live and work globally while working towards your Portuguese (and thus EU-) citizenship.

Tax Considerations in Portugal

Here’s where things get interesting for entrepreneurs:

Portugal offers the Non-Habitual Resident (NHR) program. As an NHR, you pay no Portuguese tax on certain foreign income for 10 years.

This means: If your income is structured correctly, you can combine EU residence with minimal tax.

Real-life example: One of my clients, a German management consultant, funnels his revenue through a Cypriot company. As a Portuguese NHR, he pays no tax in Portugal—and just 12.5% corporate tax in Cyprus.

Effective overall tax rate: About 15%, down from 42% in Germany.

Portugal Golden Visa: Who Is It For?

I recommend the Portugal Golden Visa to entrepreneurs who:

• Need flexibility in residence time
• Prefer a professionally managed investment
• See tax optimization as a strategic priority
• Are patient enough to wait five years for EU citizenship
• Want an established, low-risk route

If this sounds like you, Portugal is likely your best bet.

But there are also alternatives.

Malta Individual Investor Programme: The Premium Option for EU Citizenship

Malta is the last EU country to still offer direct citizenship by investment.

That makes it exclusive—and expensive.

Malta IIP After the 2021 Reforms

Malta’s program underwent fundamental reform under EU pressure. The main changes:

• Residence requirement: At least 12 months genuine residency before citizenship
• Stricter due diligence: More robust background checks and source-of-funds audits
• Tiered pricing: €1,000,000 for 36 months residence, €750,000 for 12 months
• Additional investments: €700,000 in property or €16,000/year rental + €150,000 government bonds

Total cost is in the region of €1.4–1.8 million, depending on your chosen option.

When Malta Makes Sense Despite the High Price Tag

At these prices, you’re probably asking: Who is Malta actually suitable for?

In my experience, there are three types of entrepreneurs:

1. Time-sensitive investors: 12–36 months is still much quicker than Portugal’s five years
2. Tax-optimized residency: Malta offers attractive tax structuring for international business owners
3. English-speaking preference: Malta is the only fully English-speaking EU country

Malta’s Tax Advantages for International Entrepreneurs

This is where Malta shines: Malta’s tax system is built for international business.

The most important benefits:

• No taxation on foreign income: So long as it’s not remitted to Malta
• 6/7ths refund system: Effective corporate tax of 5% for Maltese companies
• EU tax advantages: Access to all EU double taxation treaties
• Participation exemption: Dividends and capital gains from shareholdings are often tax-free

Example: A tech entrepreneur with software licenses sets up via a Maltese holding company. Royalty income is taxed at 5%, and dividend payments are often entirely tax-free.

This works because Malta, as an EU member, has full access to EU tax benefits.

Malta IIP: How to Put It into Practice for 2025

If you’re considering the Malta option, here’s a realistic timeline:

All in all, you should allow for 2–4 years—and be ready to actually live in Malta.

That’s the reality of Malta’s “new” citizenship route.

Greece Golden Visa: Residency through Real Estate Investment

Greece offers the EU’s most affordable Golden Visa program.

But affordable doesn’t always mean the best choice.

Greece Golden Visa: The Basics

The Greek program is as simple as it gets: A €250,000 property investment = 5-year residence permit for the whole family.

The key benefits at a glance:

• Lowest investment threshold: Only €250,000 required
• No residence requirement: You don’t need to live in Greece
• Family inclusion: Spouse and children under 21 are automatically included
• Unlimited renewals: As long as you own the property
• EU travel freedom: Schengen access without a visa

All sounds great. But there are some significant downsides.

The Hidden Pitfalls of the Greek Program

Let’s be honest: The Greek Golden Visa has built-in weaknesses that many providers gloss over.

Issue 1: Long wait for citizenship
You need seven years of continuous legal residence before you can apply for Greek citizenship. That’s longer than any other EU program.

Issue 2: Language requirements
To get citizenship, you have to learn Greek—a major obstacle for most international business owners.

Issue 3: Limited tax advantages
Greece has no special tax regime for Golden Visa holders. If you become a tax resident, you’ll pay standard Greek rates—up to 44% on income.

Issue 4: Real estate market risk
Your visa is directly tied to the property. Sell it, and you lose your status.

When Greece Still Makes Sense

Despite the drawbacks, I recommend the Greek program in two specific situations:

1. As a backup option: In addition to another EU program
2. For property enthusiasts: Those genuinely interested in Greek real estate

Real-life example: An entrepreneur family takes the Portugal Golden Visa as their primary path, and also buys a small €250,000 apartment in Thessaloniki. The Greek visa serves as a backup route and vacation home.

Total cost: €750,000 (€500,000 Portugal + €250,000 Greece) for two EU residencies and maximum flexibility.

Greek Property: Market Assessment 2025

If you’re considering Greek real estate, here’s my realistic market insight:

My recommendation: If you choose Greece, choose Athens or select islands. Anywhere else is just a gamble.

Strategic Reorientation: My Recommendations for a Post-CIP World

After five years of post-CIP experience, I’ve developed three strategies that work for different types of entrepreneurs.

Which one fits you?

Strategy 1: The “Portugal-First” Approach (Recommended for 70% of My Clients)

This is what I implement for most strategically-minded entrepreneurs:

Phase 1 (Years 1–2): Setting Up the Portugal Golden Visa

• €500,000 investment in a Portuguese fund
• Apply for NHR for tax optimization
• Meet minimum residence requirement (7 days in year one)
• Set up international business structures

Phase 2 (Years 3–5): Establishing Residency

• Gradually spend more time in Portugal
• Build business network in the EU
• Move tax residence to Portugal
• Anchor family life in the EU

Phase 3 (Year 5): EU Citizenship

• Apply for Portuguese citizenship
• Withdraw investment from the fund (ideally with profit)
• Complete EU integration

Total cost: Approximately €600,000–700,000 over 5 years
Outcome: EU passport, optimized tax structure, ROI on investment

Strategy 2: The “Malta Express” Approach (For Time-Sensitive Entrepreneurs)

This is for entrepreneurs who need EU citizenship quickly:

Phase 1 (Months 1–6): Setting Up in Malta

• Due diligence and application submission
• €150,000 in Maltese government bonds
• Buy property (€700,000) or rent (€16,000/year)
• Set up tax structures

Phase 2 (Months 7–18): Genuine Residency

• Spend at least 12 months physically in Malta
• Build or shift business to Malta
• Tax optimization via Maltese companies
• Integrate into the Maltese community

Phase 3 (Months 19–24): Citizenship

• €750,000 citizenship payment
• Final due diligence and interviews
• EU passport within 24 months

Total cost: €1.4–1.8 million
Outcome: EU passport in 24 months, optimized tax structure

Strategy 3: The “Diversification” Approach (For Maximum Flexibility)

This strategy combines multiple programs for maximum options:

Base: Portugal Golden Visa (€500,000)

• Primary route to EU citizenship
• NHR status for tax efficiency
• Professional investment management

Plus: Greece Golden Visa (€250,000)

• Backup EU residency
• Real estate diversification
• Extra flexibility

Optional: Third-country programs

• Dubai Golden Visa (€200,000) for tax residency
• Or Singapore, Canada, as needed

This strategy costs €750,000–1,000,000, but offers maximum geographic and tax flexibility.

Which Strategy Suits You?

Your decision depends on three factors:

1. Timeline: How quickly do you need EU access?
2. Budget: What level of investment makes sense?
3. Lifestyle: How flexible are you about your whereabouts?

My recommendation: 70% of my clients succeed best with the “Portugal-First” approach.

Why? It offers the best balance of cost, flexibility, and likelihood of success.

Tax Considerations: What Changes with the New Programs

This is where things get truly relevant for a strategically-minded entrepreneur: How do you optimize your tax burden in a post-CIP world?

The short answer: Better than ever before.

Let me explain the longer version.

Portugal NHR: The Underestimated Tax Gem

The Portuguese Non-Habitual Resident program is arguably Europe’s best tax tool.

How it works:

As an NHR, for 10 years you pay:

• 0% tax on foreign pensions
• 0% tax on foreign rental income
• 0% tax on certain foreign business income
• 20% tax on Portuguese employment income from “high value activities”
• 28% tax on capital gains (with exceptions)

Here’s a practical example:

Klaus runs a German consulting firm and earns €300,000 annually. Instead of 42% German taxes, he pays as a Portuguese NHR:

• Consulting income routed via Cypriot company: 12.5% corporate tax
• Dividend payout to Portugal: 0% (as foreign income)
• Total tax: 12.5% instead of 42%
• Annual saving: €88,500

Ten years of NHR status: €885,000 in tax savings.

The NHR program alone justifies the Portugal Golden Visa.

Malta: Tax Haven with EU Perks

As an EU member, Malta offers unique tax advantages for international business.

Main structures:

1. Maltese Holding Structure

• Corporate tax: 35% nominal, but 30% refund available
• Effective tax: 5% on distributed profits
• Participation exemption: Dividends and capital gains often tax-free

2. Maltese Residency Non-Domiciled Status

• No tax on foreign income (if not remitted to Malta)
• Only Maltese-sourced income is taxed
• Access to EU tax treaties

Example: A tech entrepreneur licenses IP out of Malta:

• German company transfers IP to Maltese entity
• Maltese company licenses IP globally
• Royalties taxed at 5% in Malta
• Dividends distributed EU-wide with optimal structure

Tax Planning for Post-CIP Strategies

The key insight: Modern investment migration is always about tax planning as well.

Here’s my tried and tested structure for Portugal-based strategies:

This setup enables:

• EU compliance via Portuguese tax residency
• Tax optimization through Cypriot IP holding
• NHR benefits for capital income
• Protection from CRS and international tax agreements

The Most Common Tax Mistakes in Investment Migration

After five years, I see the same errors repeatedly:

Mistake 1: Residency without tax planning
Many entrepreneurs apply for a Golden Visa but don’t adjust their tax setup—ending up double-taxed or with an unfavorable tax burden.

Mistake 2: Timing errors
Tax residence changes must be strategically timed. Bad timing can easily cost six figures.

Mistake 3: Lack of substance
Tax optimization without real economic substance is risky—the OECD is tightening rules constantly.

Mistake 4: Neglecting compliance
Different countries have different reporting requirements. Missed filings lead to penalties or loss of program eligibility.

My advice: Tax planning should be part of your investment migration strategy right from the start.

Practical Implementation: Your Action Plan for 2025

Enough theory—let’s get practical.

Here’s your step-by-step roadmap to a successful investment migration strategy in the post-CIP world.

Phase 1: Strategic Analysis (Months 1–2)

Step 1: Assess Your Current Position

Before you apply to any program, you need to understand where you currently stand:

• Tax situation: What’s your current burden, and the optimization potential?
• Business structure: How complex are your corporate structures?
• Family situation: Spouse, children, their needs
• Liquidity: Available capital for investment
• Time frame: How urgent is your need for EU access?

Step 2: Define Your Goals

What do you really want to achieve?

• EU citizenship as insurance
• Tax optimization and cost reduction
• Business expansion into the EU
• Educational opportunities for children
• Geographic diversification

Step 3: Selecting the Right Program

Based on your analysis, pick the suitable program:

Phase 2: Preparation and Application (Months 3–6)

Portugal Golden Visa: Step-by-Step

A realistic timeline:

1. Month 1: Fund selection and due diligence
   • Select a qualified Portuguese fund
   • Legal and tax advice
   • Prepare documents (apostilled and translated)
2. Month 2: Investment and application
   • €500,000 investment in chosen fund
   • Apply for Golden Visa at SEF (Portuguese immigration)
   • Provide biometrics and interview
3. Months 3–6: Processing and approval
   • Wait for authority review
   • Apply for NHR at the same time
   • Set up tax structures

Malta IIP: Step-by-Step

Malta is more complex:

1. Months 1–2: Due diligence prep
   • Comprehensive background checks
   • Proof of source for all assets
   • Legal opinion of your eligibility
2. Months 3–4: Application
   • Full application to Identity Malta
   • €150,000 investment in government bonds
   • Property purchase or rental agreement
3. Months 5–12: Establish residency
   • Build physical presence in Malta
   • Shift business activity to Malta
   • Integrate and join community

Phase 3: Optimization and Integration (Years 1–5)

Tax Optimization

Alongside securing residency, refine your tax structures:

• Year 1: Prep for tax residence switch
• Year 2: Set up international structures
• Years 3–5: Fine-tune and optimize your structure

Business Integration

Use this period for strategic business growth:

• Expand your EU client base
• Develop local partnerships
• Upgrade compliance and governance
• Build your EU-based team

Common Pitfalls—and How to Avoid Them

Pitfall 1: Incomplete documentation
Solution: Create a checklist and get professional support

Pitfall 2: Underestimating the residence requirement
Solution: Plan realistically and integrate gradually

Pitfall 3: Tax traps
Solution: Seek early tax advice in all countries involved

Pitfall 4: Due diligence issues
Solution: Be transparent and professionally prepared

Your Next Steps

If you’re seriously considering investment migration, I recommend this path:

1. Strategic advice: Have an expert review your case
2. Tax assessment: Understand your optimization potential
3. Compare programs: Evaluate all relevant options
4. Develop a timeline: Craft a realistic plan
5. Professional execution: Work with experienced advisors

The investment migration landscape may have changed since the CIP suspension. But for the strategically-minded entrepreneur, it now offers more opportunities than ever.

The question isn’t whether you should position yourself internationally.

The question is: When will you start?

Yours, RMS